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"Best Interest" Training Requirement from NAIC for Annuity Product Sales

  • Writer: LIR TEAM
    LIR TEAM
  • Sep 27
  • 4 min read
Two people shake hands in a blue-tinted room. Focus on a card reading "CLIENT." Text: "MUST PUT CLIENTS FIRST, NOT BUSINESS INTERESTS."
LIR is committed to make this life insurance and annuity sales industry better for the client & consumer.

The National Association of Insurance Commissioners (NAIC) introduced the "Best Interest" Training Requirement from NAIC for Annuity Product Sales in 2020. As of April 2025, it has officially become the standard across all U.S. states. This move was long overdue, as annuities—especially Fixed Index Annuities (FIAs)—are among the most complex financial products sold to consumers. But while the rule is a step forward, it is not enough on its own to protect consumers.


This is why working with an independent, licensed Life Insurance Analyst and securing a second opinion from LifeInsuranceReview.com (LIR) remains critical. At LIR, more than 8 out of 10 annuities reviewed reveal areas for improvement or replacement with better alternatives.


How Annuity Suitability Was Upgraded to Best Interest

Before 2020, the annuity sales framework was based largely on “suitability.” Under those rules, an annuity only needed to be “suitable” based on limited information about the consumer. Unfortunately, this left room for abuse, manipulation of illustrations, and overselling by commission-driven agents.


With the Best Interest Model Regulation, the standard has been elevated to require:

  • Consumer Profile Information collection (more comprehensive than suitability data).

  • New disclosure forms requiring consumer signatures if they refuse to provide information or buy against recommendations.

  • A focus on consumer needs over producer commissions.


The Four Best Interest Obligations

Under the NAIC model, producers must follow four obligations when recommending annuity products:

  1. Care Obligation – Recommendations must be based on objective evaluation of the consumer’s financial profile.

  2. Disclosure Obligation – Consumers must receive clear disclosures about product features, risks, costs, and conflicts.

  3. Conflict of Interest Obligation – Agents must identify and mitigate any personal financial incentives that could bias recommendations.

  4. Documentation Obligation – Detailed records must support why a recommendation is in the consumer’s best interest.


While this framework is designed to protect consumers, it still relies on agents and insurers to enforce it—and their financial incentives are often misaligned.


Why Consumers Still Need an Independent Second Opinion

Even with the "Best Interest" Training Requirement from NAIC for Annuity Product Sales in place, consumers should not assume they are fully protected. Here’s why:

  • Complexity of products – FIAs and IULs include moving parts (caps, spreads, participation rates, COI charges) that most consumers—and even many agents—don’t fully understand.

  • Illustration manipulation – Sales presentations often highlight best-case assumptions without stress testing or realistic projections.

  • Agent incentives – Commissions remain a driving factor in product selection.

  • Alternative strategies – Independent review often reveals better, lower-cost, or more flexible options.


By partnering with LifeInsuranceReview.com (LIR), both consumers and professionals (CPAs, attorneys, advisors) gain an independent, fiduciary-style analysis. LIR’s proprietary 28-Point Review Checklist ensures annuity and life insurance policies are tested thoroughly—not just “sold.”


Why Professionals Trust and Refer Clients to LIR

CPAs, estate planning attorneys, and financial advisors consistently trust and refer their valued clients to LifeInsuranceReview.com (LIR) because of the independent expertise and fiduciary-style oversight we provide. Unlike agents and brokers who are motivated by commissions, LIR’s focus is entirely on protecting the client’s best interests.


Professionals rely on LIR because:

  • Independent objectivity – LIR is not tied to commissions or carrier incentives. Our analysis is impartial and consumer-driven.

  • Proven expertise – With decades of licensed experience and a rare Life Insurance Analyst license, LIR provides insights that most insurance professionals cannot.

  • Client protection – By ensuring policies are reviewed with our 28-Point Checklist, professionals can be confident their clients avoid costly mistakes and unnecessary risks.

  • Practice enhancement – Referring to LIR elevates the professional’s credibility, showing clients they have a trusted partner for complex insurance evaluations.


For these reasons, professionals across the country place their trust in LIR as the go-to resource for independent second opinions on annuities and life insurance policies.


Conclusion - "Best Interest" Training Requirement from NAIC for Annuity Product Sales

The NAIC Best Interest Training Requirement is a positive step forward, but not a complete solution. Consumers must still protect themselves by seeking an independent second opinion before buying or keeping an annuity. By working with a licensed Life Insurance Analyst and LifeInsuranceReview.com (LIR), clients gain the confidence that their annuity purchase truly aligns with their financial goals—not just the agent’s commission goals.


FAQs About the NAIC Best Interest Requirement for Annuities

1. What is the NAIC Best Interest Training Requirement?

It’s a nationwide standard that requires insurance producers to act in the consumer’s best interest when recommending annuity products, effective in all states as of April 2025.

2. How does “Best Interest” differ from “Suitability”?

Suitability only required basic matching of a product to consumer goals. Best Interest requires deeper data collection, full disclosure, and documentation to prove the recommendation benefits the client—not just the producer.

3. Does the Best Interest rule eliminate conflicts of interest?

No. Agents are still commission-based. The rule requires disclosure of conflicts but does not eliminate them. That’s why independent reviews remain critical.

4. Why are Fixed Index Annuities (FIAs) and IULs considered complex?

These products involve moving parts like crediting rates, caps, spreads, bonuses, and rising insurance costs. Small changes can drastically affect long-term performance.

5. How can professionals benefit from referring clients to LIR?

By partnering with LIR, CPAs, attorneys, and advisors strengthen their role as trusted fiduciaries, prevent client poaching by agents, and ensure policies are properly reviewed.

6. How often should an annuity be reviewed?

Every 2–3 years at minimum—or sooner if market conditions, product terms, or personal financial goals change.

We had a survivorship policy for about 6 years and when I got my policy reviewed, I learned that I can apply for a new policy with another company via 1035 exchange with $1.6M higher coverage and longer guarantee age. This was because I was also a pilot with now more than 900hrs, and that I qualified for the best health rating at some insurance companies. Our original agent never bothered to follow-up with us to explore any other options, except to make sure we were paying our annual premiums.

Steve & Pat L., CA

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